Consumer Duty

Ecommerce Technologies LTD (“PayDo”) is a regulated Electronic Money Institution (“EMI”). PayDo is the manufacturer of financial services – it creates, develops, designs, issues, manages, operates the products/services, is responsible for developing the terms, features, and pricing of the products, and also distributes* it on its own.

* –  Sometimes we get business prospects from the legal consultants and incorporators acting as our distributors, which could provide limited preliminary consultation to the customers.

This Consumer Duty acts as an explanation for how we deliver good outcomes for retail customers. It considers the needs, characteristics, and objectives of our customers including those with characteristics of vulnerability – how we behave, at every stage of the customer journey.

The four main consumer outcomes relate to:

• Products and services
• Price and value
• Consumer understanding
• Consumer support

We believe that an enhanced focus on consumer outcomes will help to build strong relations with you.

Our Target market

PayDo offers its products and services through an online platform. Our customers can create accounts, load funds, and conduct transactions online.

We provide solutions for both retail clients and micro-enterprises, and SME businesses. Signing up on PayDo, every customer gets personal or business accounts and can easily switch between them. Depending on current needs, demands, and types of activity, a customer proceeds with one of the account types.

We are focusing on expanding internationally SME businesses whose main activity is connected with providing goods or services online. We are keen to onboard both incorporated firms and sole entrepreneurs that face unique challenges regarding cross-border payments, as international transactions can be complicated, time-consuming, and expensive, creating barriers to growth and success.

Our target customers:

Our products are more suitable for the customers who are planning to have at least 5 transactions per month.

We do not provide services to the Charities and Financial Institutions. PayDo also does not cooperate with companies/individuals whose legal, actual or address of residence of the executive (beneficiary/director) is located in the following countries

• Countries that are subject to sanctions, embargoes or similar measures imposed by the UN, Financial Action Task Force on Money Laundering.
• According to reliable sources, countries that do not have relevant laws, regulations for the prevention of money laundering (AML) / terrorist financing (CFT).
• According to reliable sources, countries are characterised by high levels of corruption or other illegal activities.
• Countries whose residents create an increased organisational / financial burden on the company due to a complex legal or specific tax system.

PayDo does not provide its services to the companies that offer the following services:

• Services that, according to reliable sources or classification of competent authorities, are potential scams.
• Online education of forex trading.
• Services provided through international correspondent bank accounts, including transactions such as payments to non-customers (e.g. intermediary banks) and postal money transactions.
• International private banking services.
• Services related to bonds, precious metals and anonymous services.
• Services, providing file storage on the web hosting / servers.
• VPN servers.
• Services that enable instant international transactions such as online bank transfers, letters of credit, bills of exchange, international wire transfers, private equity firms, and funds.
• Charity funds, charitable organisations, foundations, organisations collecting donations, crowdfunding organisations.
• Arms and ammunition trade.
• Medicines, Pharma, bio-active additives.
• Precious metals, stones, diamonds.
• Works of art.

In addition to the above-mentioned prohibited activities, PayDo services are not the best fit for the following customers:

• Personal customers who want to get classic retail banking services (savings account, credit card issuing, loans, etc.) as we do not provide credit lines and overdrafts.
• SMEs focused on the local market of their country of incorporation and don’t have plans for international expansion.
• SMEs that main activity is conducted offline with a limited online presence.
• SMEs that have an annual turnover of less than 400’000 GBP.Require holding, buying, and selling cryptocurrencies.

If you feel you are not within the above target market we highly suggest you to compare PayDo with other alternatives: banks, neobanks, or EMIs, which could appear to be more suitable for your case.

Understanding fair value

Our products and services provide fair value.

PayDo considers the fair value assessment at every stage of the product approval process, including in particular when:

1. Designing the product;
2. Identifying retail customers in the target market for whom the product needs to provide fair value (i.e. when the new retail segment is identified);
3. Selecting distributions methods/channels.

As a manufacturer we are:

1. Conducting business with integrity: PayDo is required to conduct its business with integrity, ensuring that we act honestly, fairly, and professionally in all their dealings with customers and other market participants.
2. Treating customers fairly: PayDo ensures that its products and services are designed and marketed in a way that takes into account the best interests of customers. This includes providing clear and transparent information, suitable advice (mainly applicable for business clients, but any client is welcome to ask our support team for assistance and clarifications plus the clients always pass our onboarding process), and fair treatment throughout the customer journey.
3. Managing conflicts of interest: PayDo has appropriate policies and procedures in place to identify and manage any conflicts of interest that may arise in their business operations. This is to ensure that the interests of customers are not compromised by any conflicting interests.
4. Maintaining adequate financial resources: PayDo maintains adequate financial resources to meet its obligations and ensure its financial stability. This includes having sufficient capital and liquidity to cover potential risks and liabilities.
5. Ensuring appropriate systems and controls: PayDo has effective systems and controls in place to identify, manage, and mitigate risks. This includes implementing robust risk management frameworks, internal controls, and governance arrangements to ensure the proper functioning of our business operations.
6. Complying with relevant laws and regulations: PayDo complies with all applicable laws, regulations, and regulatory requirements relevant to our business activities. This includes staying updated on any changes in the regulatory environment and adapting our operations accordingly.

Assessing value

PayDo places great importance on assessing the value it provides to its customers. This entails considering not only the financial costs and benefits but also the broader non-financial aspects that contribute to the overall customer experience. We are not aware of any significant non-financial costs to retail customers in the target market for our products.

When evaluating the costs, PayDo takes into account factors such as transaction fees, account maintenance charges, country of residence (or incorporation for business clients), occupation or business activity, and any other financial obligations imposed on customers. It aims to ensure that these costs are reasonable and transparent, providing clarity to customers about the charges associated with their services.

In terms of benefits, PayDo considers the convenience, accessibility, and efficiency of its payment solutions. This includes the ease of use of its electronic money accounts, the availability of multiple payment methods, and the speed of transactions. PayDo strives to deliver a seamless and user-friendly experience to enhance customer satisfaction.

Furthermore, our institution recognizes that non-financial aspects play a vital role in assessing value. This includes factors such as data security and privacy protection, customer support and assistance, and the overall reliability and trustworthiness of the institution. We aim to maintain robust security measures to safeguard customer data and provide prompt and responsive Customer Support to address any queries or concerns.

By taking a holistic approach to assessing value, PayDo seeks to ensure that its products and services deliver tangible benefits to customers while minimising any associated costs. This enables customers to make informed decisions and derive maximum value from their interactions with the institution.

Our monthly expenses are big enough. In order to provide the services for the customers we finance monthly software development, sales and marketing, support and risks team, also for legal and other consulting, fees for banking and financial partners, office rent, etc.

A high quality of product and level of consumer service for PayDo can be assessed based on several key elements. The following are considered indicators of high product quality and consumer service:

1. Reliability and Security: PayDo prioritizes the reliability and security of its systems and services. This includes implementing robust security measures to protect customer data and funds, as well as ensuring the availability and stability of its platform.
2. Transparency and Disclosure: PayDo prioritizes transparency in its communications and dealings with consumers. This includes providing clear and understandable information about their products and services, the features, fees and charges, terms and conditions, as well as any associated risks. This also includes disclosing any applicable charges, transaction limits, and any other relevant terms and conditions.
3. Fairness: PayDo ensures that its practices and interactions with consumers are fair. This includes treating customers fairly throughout the customer journey, including product design, marketing, sales, and post-sales service.
4. Ease of Use: PayDo’s products and services are designed with a focus on user-friendliness and ease of use. This entails providing intuitive interfaces, simple account management processes, and clear instructions to enable customers to navigate and utilize the services without difficulty.
5. Customer Communication: PayDo communicates with customers in a clear, timely, and appropriate manner. This includes providing accessible channels for customers to seek assistance or raise concerns and addressing customer queries or complaints promptly and effectively.
6. Suitability: PayDo assesses the suitability of its products and services for individual customers, taking into consideration their needs, circumstances, and financial capabilities. This includes providing suitable advice (if applicable) and offering products and services that align with customer requirements.
7. Payment Options and Flexibility: PayDo offers a variety of payment options to cater to the diverse needs and preferences of customers. This includes support for different payment methods, integration with digital wallets, and the ability to make payments in multiple currencies.
8. Customer Support: A high level of consumer service involves responsive and helpful customer support. PayDo has accessible channels for customers to seek assistance, such as email or live chat, and strives to resolve customer queries or issues in a timely and satisfactory manner.
9. Compliance with Regulations: PayDo demonstrates compliance with the regulatory requirements set by the FCA and other relevant authorities. This includes adhering to anti-money laundering (AML) and Know Your Customer (KYC) regulations and maintaining Safeguarding accounts that hold customers’ money in full, as well as implementing robust systems for fraud prevention and detection.
10. Complaints Handling: PayDo has high consumer service and values effective complaints handling. PayDo has a transparent process for receiving, investigating, and resolving customer complaints, aiming to address issues fairly and promptly in a timely manner.
11. Vulnerable Customers: PayDo pays particular attention to the needs and protection of vulnerable customers, such as those with disabilities, low financial literacy, or other specific vulnerabilities. This involves providing additional support, accessibility measures, or tailored services.

As stated in FG22/5, to assess if a product or service provides value, PayDo considers at least the following:

• The nature of the product or service, including the benefits that will be provided or may reasonably be expected and their qualities
• Limitations that are part of the product or service (eg limitations for risks)
• The expected total price customers will pay, including all applicable fees and charges over the lifetime of the relationship between customers and firms.

To provide a high level of service we invest much in our human resources and technology which is forming the price the client gets.

A high-quality product and level of consumer service for PayDo involve a combination of reliability, transparency, user-friendliness, support, compliance, and effective complaints handling. By excelling in these areas, PayDo builds trust with its customers and delivers a positive experience.

Our pricing approach is based on the net price of our correspondent banks and financial partners, our competitor’s price for typical “easy-come” clients + costs of extra processes + markup for more complex business models,/value/outcome we give to the customers.

We use a so-called Premium Strategy provisioning multiple services for digital, cross-border industries through 1 platform, and 1 contract with a transparent and easy-to-understand set of fees.While some of our fees may be above market, we do not charge multiple fees, side fees, or hidden services.We do not charge any extra fees for multiple product usage  (PayDo business account, PayDo checkout, and PayDo mass payments).

Our typical customers are willing to pay a premium for a superior product. In our case, the higher quality means the individual approach we use when verifying clients with more complex business models (ex. the clients who are in digital products industries or/and providing their services internationally, including outside of lower-risk markets and countries, requiring more advanced monitoring tools and measures (such as anti-fraud tools for digital goods merchant accounts).

Most of our competitors ignore such clients, do not onboard them, or require solid financial commitments from their side, or impose various side fees. At the same time, we use more external information resources and spend more time for such checkings which means extra costs which we need to cover with extra margin.

Price = Basic Price + Extra costs of Sales & Marketing = extra costs of acquiring, finding niche clients within the target market +  Extra costs of account monitoring and ensuring compliance + Extra costs of support +   Markup1 (which also includes the future risk of additional processes related to more risky clients)

1. Basic price – The ordinary price of our correspondent banks and financial partners and/or other competitors provide for the typical clients (we take an average price of the for the mass market clients).
2. We pay an extra fee to acquire specific more risky clients.

For business customers, we also have extra markup (Markup2) which is higher compared with individual customers because of additional SLA, more onboarding resources required, more services and products being provided + 24/7 support.

At the same time PayDo:

• Has Minimum side fees (our competitors generally have 10-16 additional fees, on which they earn, thus partly hiding some costs which are not so easy for the customers to predict in advance). PayDo has a minimal number of such fees, and no fees for holding funds.
• Supports digital and other more complex industries
• Provides Dedicated Account management and Live chat support.

For merchants we also add the following costs to the price: Website checkings + consulting related to integration.

We revise/decrease the price when we receive a massive amount of feedback from the clients stating that the price is not fair and our sales work with objections doesn’t help (it occurs rarely).

The lifetime of the individual client is shorter compared with the business client which is also considered when forming the price.

Besides that, when existing or transferring away we may ask you to pay a fee for closing accounts because it involves administrative work and expenses plus various backend processes, including verifying the account holder’s identity, processing the closure request, checking the balance, if everything is in order with your transactions, updating databases, reporting, and ensuring that all transactions and financial records are accurately closed.
Updating records, and ensuring compliance with regulatory requirements. These processes require time and resources, contributing to the cost.

Contextual factors

PayDo also considers the following contextual factors relevant to value:

1. Market Prices for Similar Products and Services: PayDo assesses the value it provides by considering the prevailing market prices for similar products and services. This involves examining the pricing structures of competitors or comparable offerings to ensure our pricing is fair and competitive.
2. Consumer Characteristics in the Target Market: PayDo takes into account the characteristics of its target market when evaluating value. This includes understanding the needs, preferences, and financial capabilities of our consumer base. Tailoring products and services to meet these characteristics can enhance value perception.
3. Fairness of Pricing Structure: PayDo critically assessed the fairness of its pricing structure. This involves ensuring that the fees, charges, and pricing mechanisms are transparent, reasonable, and proportionate to the value provided to consumers. Our pricing is clear and understandable, and any potential hidden costs or complex fee structures are minimized.
4. Comparative Assessment: PayDo conducts comparative assessments to evaluate the value we offer. This involves benchmarking our products and services against industry standards, best practices, or consumer expectations. Such assessments help us to identify areas for improvement and enhance the overall value proposition.
5. Consumer Feedback and Satisfaction: PayDo considers consumer feedback and satisfaction as important contextual factors. Monitoring and analyzing customer reviews, complaints, and satisfaction surveys provide valuable insights into how consumers perceive the value of our products and services. Addressing customer concerns and actively seeking feedback help us improve value delivery.
6. Evolving Market Conditions: PayDo needs to consider the dynamic nature of the market and adapt its value proposition accordingly. This includes monitoring market trends, technological advancements, regulatory changes, and other external factors that impact the value we provide. By staying responsive to evolving market conditions, PayDo makes its best to meet consumer needs and expectations.

Assessing differential outcomes

We consider the potential impact of differential pricing or outcomes for different groups of consumers and the additional considerations this creates for PayDo’s fair value assessments.

In the context of differential pricing, where certain customer segments are charged different fees or offered different pricing structures, PayDo carefully evaluates the fairness and justification of such differentials. This assessment ensures that the differential outcomes are reasonable and do not result in unfair treatment or disadvantage for specific customer groups.

When segmenting customers, PayDo considers a range of factors to differentiate between different customer segments. Some customer segmentation criteria in the context of medium and high-risk clients include:

1. Risk Profile: PayDo segments customers based on their risk profiles, such as low, medium, and high risk. This segmentation determines the level of due diligence and monitoring required for each segment. Our target market is medium and high-risk clients which are subject to enhanced due diligence measures and stricter transaction monitoring, which results in an additional fee to cover the associated costs.
2. Transaction Volume: PayDo segments customers based on their transaction volume. Those with higher transaction volumes require more extensive monitoring and oversight, which results in a differentiated pricing structure.
3. Service Level: PayDo offers higher service levels based on the specific needs and preferences of customers which is higher compared with our competitors. PayDo provides Business accounts, mass payments, and merchant services in 1 dashboard, through 1 online portal. Customers with complex business models such as marketplaces, digital goods, and international trading companies potentially opt for a more comprehensive and costly service level from technical support, compliance, account management, live support, integrations, and setup point of view.
4. Product Usage: Segmenting customers based on their usage patterns or product preferences is another approach. PayDo offers specialised services and tailored solutions for customers engaged in specific industries or requiring specific functionalities. The pricing for these specialised services may vary based on the unique requirements of each customer segment.

It is important for PayDo to ensure that any differential outcomes or pricing for different customer segments are reasonable, transparent, and proportionate. Fair value assessments take into account the additional considerations associated with differential outcomes, such as the costs of extended due diligence and transaction monitoring for medium and high-risk clients. PayDo also communicates the rationale behind the differential pricing and outcomes clearly to customers to maintain transparency and fairness in their interactions.

Our products outcomes and benefits for the customers

PayDo provides a unique payment platform with a combination of neobanking, local and international money transfers, anti-fraud, checkout merchant services, and mass payments in one interface, one digital contract and one point of contact both for personal and business.

Depending on customer’s needs, PayDo offers:

• Personal account which allows digitalise customer’s funds and pay securely online on your favourite website.
• Business account for SMEs which helps with the quick start of online business and provides an efficient way to expand international trading with new customers by accepting and sending money transfers safely in most countries of the world.
• Mass Payments for SMEs and corporations
• PayDo checkout (merchant services)for SME and corporations

Main features of PayDo Business Account

• Multi jurisdictional IBANs (UK, DE, DK IBANs) and UK and DK local accounts with sort codes, money transfers and FX
• Fully online, paperless services
• Advanced and user friendly online platform
• Money transfers
• Multi-currency account – more than 20 currencies
• Convenient, transparent and cost effective currency conversion with MID market rates and transparent mark-ups available prior to any FX operations provided by global banking partners

Benefits:

• Fully online usage without physical presence in the country you may be doing business with
• Available for local and international, friendly for cross border business
• Multi-currency accounts
• Transparent FX
• Collections in local and international accounts (e.g. company from the Germany may open an account with us and receive UK, EU bank details, trade without borders and limits)
• Fully transactional service and SME friendly – no minimums, no commitments, no deposits
• Leading user experience, convenient dashboard, easy navigation in comparison to most of classic banks (the client may do most of things as self-care instead of long waiting of the support and back-office specialists)
• Automatisation of the processes
• Accounts statements and references instantly, any time and expertise of the team, transparent onboarding of supported industries
• All popular payment routes – Cross-border, SEPA, TARGET2, FPS, serving more than 120 countries
• Advanced platform and merchant services are available by default
• Monthly updates of the platform by request and feedback of our users
• All services are designed to meet the market challenges, demands and requirements.

PayDo Personal Account

• Free payments and top-ups through your favourite websites accepting PayDo.No mark-ups on top-ups of e-wallet through the dashboard- all prices are not commercial, exactly the same as we are getting from the payment partner.
• Withdrawals to Visa and Mastercard in 1 place
• 20 currencies available
• Transparent FX operations
• Free Collections of payments from popular marketplaces, and contractors in the EU, UK, and overseas. We support both local and international collections/ receivables from/to around 120 countries.
• No account maintenance fees, no account opening fee, total pay-as-you-go basis
• Leading user experience, convenient dashboard, easy navigation in comparison to most classic banks
• Semi-automated, prompt and convenient onboarding.
• No hidden fees – free account closure, account statements, and support.

Perfect solution for payments on the favourite websites of the customers and accepting payments from other PayDo customers or any other businesses. The customer will get all these bank details in one dashboard.

PayDo Checkout

It is a secure e-wallet-hosted payment page for websites providing goods/services accepting PayDo. It lets merchants quickly collect payments. It works across devices and is designed to increase conversion. End-shoppers with a registered PayDo account can log in to the account and top-up in 1 click with a linked card, PayDo wallet, or alternative payment methods, upon successful top-up, they may freely pay to the website using their account balance.If the customer does not have an account, he can immediately create one from the check-out page, verify it in two steps and complete the payment. Top-ups for the customers (end-shoppers) are displayed according to project settings and geolocation.

• The service for business customers with online websites or platforms to accept payments on their websites
• 150+ payment schemes/methods supported via single API and integration to accept PayDo e-wallet, cards, direct debits, instant banking and similar.
• Advanced payments safety guaranteed by included anti-fraud service, 1-time quick user verification.
• Users are verified just once in 1 minute, following this, they may use any of 150 payment schemes/methods in 1 click
• 1 click payments, cards link, transactional history and reports for every user.
• One of the most advanced UX of the payment page on the market.

Description:

• https://www.youtube.com/watch?v=sTh489kOMYU

PayDo Mass Payments

The service allows businesses to conduct multiple instant payments to multiple PayDo clients. The client can conduct mass payouts in their PayDo account dashboard or make them automated, integrating API into their website.

In order to conduct payments to PayDo clients, the client provides PayDo with payment instructions by entering the following payment information into the PayDo system: PayDo ID or PayDo registered email, the amount payable, and payment description.

Possibility to create UK and EU IBAN account online quickly

• You can open and manage an account remotely from the UK/EU or any foreign country*. Fill in just one application form to submit the request.
  

  * – You can open an account IBAN remotely and manage it from Europe or other countries like India, Malaysia, Singapore, except the FATF list.

• If you are a company, a PayDo business account provides you with all the benefits of a European business account without the need to have a European entity.
• Through our business account, your business can send and receive money instantly, keep funds, and exchange currencies. Companies, banks, and business partners can send funds to your account in multiple currencies.
• We will provide you with account details under your name (or business name) and bank details for multi-currency payment acceptance.
• Unlimited and free incoming SEPA, Cross-border, FPS, CHAPS & Target2 transfers. Outgoing transfers at attractive fees.
• For companies from 170+ countries – We allow you to arrange SEPA, FPS, Cross-border & Target2 transfers.
• Available anywhere.
• We provide UK, Germany and DK based IBANs.
• All accounts are multi-currency accounts (more than 20 currencies).
• Local UK account with an account number and sort code is provided.
• Local Denmark account is provided.
• Advanced and user friendly online platform.
• Fully online, paperless services management.
• Local and cross-border money transfer in more than 20 currencies and across 120 countries.
• Convenient, transparent and cost-effective currency conversion with mid-market rates provided by global banking partners.

Easy of use

• Automatisation of the processes — Accounts statements and references instantly, any time and any place.
• PayDo is an advanced platform and for business clients the merchant services are available by default.
• Fully transactional service and SME friendly – no minimums, no commitments, no deposits.
• All services are designed to meet the market challenges, demands and requirements.
• Convenient funds management.
• Fully online usage without physical presence.
• Fully transactional service friendly for personal and SME needs – no minimums, no commitments, no deposits.
• Single dashboard to cover all financial needs: process payments from end-customers as well as send and receive cross-border and local transfers in EUR, USD, GBP, AUD, CAD, DKK + 20 more currencies are yet to come.
• Improved user experience, streamlined dashboard, and intuitive navigation differentiate it from traditional banks. Self-care options minimise reliance on support and back-office assistance.
• Expertise of the team, transparent onboarding of supported industries.
• Monthly updates of the platform by request and feedback of our users.
• Leading user experience, convenient dashboard, easy navigation in comparison to most classic banks (you can do most things as self-care instead of long waiting for the support and back-office specialists).

Use anywhere

• Available for local and international, friendly for cross-border business.
• All popular payment routes – Cross-border, SEPA, TARGET2, FPS, serving more than 120 countries.
• Transparent FX.
• Multi-currency accounts available.
• Collections in local and international accounts (e.g. the company from Germany may open an account with us and receive UK, EU bank details, trade without borders and limits).

Best solutions

Alternative to the classic bank account

• Any time — we provide an utterly remote account opening and maintenance. Control your account 24/7 online without branch queries or long phone banking.
• Any type of Legal Business — you get a local UK or DK IBAN that is issued in your or your company’s name to receive payments from your clients, partners, and affiliates.
• Any country of Living / Incorporation — you can open an account in Europe or other countries except for the FATF list. Fast application approval.

Data and governance

Here are our key components related to data, governance, monitoring, and rectification processes:

1. Data Plan and Monitoring: PayDo has a clear data plan outlining the types of data we collect and use to monitor customer outcomes. This includes transactional data, customer feedback, complaints data, market benchmarks, and comparators. PayDo identifies and addresses any data gaps to ensure comprehensive monitoring.
2. Monitoring Frequency and Timelines: PayDo established clear timelines for conducting value assessments and reviews. This is determined by the expected length of time a consumer would typically keep a product or the expected renewal pattern. The assessments are conducted annually, at the time of product renewal, or when significant changes occur.
3. Rectification Processes and Responsible Roles: If PayDo identifies that a product no longer provides fair value, clear rectification processes are in place. This involves assigning specific responsible roles within the organisation to address the identified issues, such as product managers, compliance officers, or Customer Support representatives. The rectification process is timely, effective, and designed to ensure fair value is restored for affected customers.
4. Triggers for New Assessments: PayDo has established triggers that require a new assessment of fair value. These triggers are based on movements in certain internal data indicators (OKRs), changes in market conditions, customer feedback, or emerging risks. These triggers ensure proactive monitoring and allow for prompt action to maintain fair value.
5. Evidence for Fair Value Assessment: PayDo provides relevant evidence to support its fair value assessments, being transparent about its limitations. This includes market-level benchmarks, comparators, and internal data. Decision-makers get detailed information to critically review and challenge the assessment of fair value.
6. Points-based or Red/Amber/Green-style Approaches: PayDo is also using alternative approaches, such as points-based or red/amber/green-style frameworks, within its fair value assessments. These approaches assign scores or ratings to different aspects of a product or service to evaluate its fairness. Critical analysis, transparent thresholds, and detailed information are provided to decision-makers to review and challenge the assessment of fair value.
7. Evidence for Fair Value Assessment: PayDo provides relevant evidence to support its fair value assessments, being transparent about its limitations. This includes market-level benchmarks, comparators, and internal data. Decision-makers get detailed information to critically review and challenge the assessment of fair value.
8. Absolute Assessment of Fair Value: PayDo considers delivering fair value for customers in absolute terms, not just in relation to competitors or industry benchmarks. This means evaluating whether the product or service meets customers’ needs, offers reasonable pricing, and provides meaningful benefits and outcomes.

When evaluating whether a product or service offered by PayDo meets customers’ needs, offers reasonable pricing, and provides meaningful benefits and outcomes as part of the Consumer Duty framework, we consider the following steps:

• Customer Research: Conduct thorough customer research to understand our target audience, their preferences, and their needs. This can be done through surveys, interviews, focus groups, or market research. By gathering insights directly from customers, we can gain a deeper understanding of their requirements and expectations.
• Customer Segmentation: Segment our customer base based on demographic, behavioural, or other relevant factors. This segmentation allows us to tailor our product or service offerings to specific customer groups, ensuring a better fit with their needs and preferences.
• Product / Service Design: Ensure that our product or service is designed with a customer-centric approach. Consider the pain points, challenges, and desires of our target customers when developing or refining our offerings. Incorporate features and benefits that address these needs and differentiate our product or service from competitors.
• Pricing Analysis: Evaluate the pricing of our product or service by considering factors such as market benchmarks, competitor pricing, cost structures, and value delivered. Conduct a pricing analysis to determine if our pricing is reasonable and aligned with the perceived value of our offering. Assess whether the pricing structure allows for a fair exchange between the customer and our organisation.
• Value Proposition: Clearly articulate the value proposition of our product or service. Identify and communicate the benefits and outcomes that customers can expect to receive. This includes not only the core features but also any additional value-added services or benefits that differentiate our offering. Make sure that the value proposition resonates with customers and addresses their needs effectively.
• Feedback and Monitoring: Continuously gather customer feedback and monitor customer satisfaction levels. Encourage customers to provide feedback on their experiences with our product or service. Monitor customer satisfaction metrics, such as Customer Satisfaction Score (CSAT) or customer reviews, to identify areas for improvement and ensure that our offering meets customers’ evolving needs over time.
• Review and Adaptation: Regularly review our product or service to assess its performance against customer needs and expectations. Identify areas for improvement and adapt our offerings accordingly. This iterative process ensures that we are continually refining and enhancing our product or service to meet customers’ changing requirements.
• Compliance and Regulations: Ensure that our product or service meets all relevant regulatory requirements and industry standards. Compliance with consumer protection regulations, data privacy laws, and any specific regulations applicable to our industry is crucial to building trust and ensuring fair treatment of customers.

Our reasonably foreseeable period of product assessment – 1 year if no significant events (triggers) occur before like price changes of the competitors, high inflation, growth of customers churn (closing accounts), etc.

PayDo doesn’t have closed products at the moment. As soon as we have them, we will provide fair treatment, ongoing support, and service to existing customers holding closed products, ensuring that their needs and interests are properly addressed throughout the product life cycle (same as for existing products). This will include providing appropriate information, disclosures, and ongoing support to existing customers, even if the product is no longer available for new customers.

Where PayDo identifies in its review of its value assessment that the product no longer provides fair value, it takes appropriate action to:

1. Mitigate, and where appropriate, remediate any harm caused to existing retail customers
2. Prevent harm to new retail customers.